A real estate transaction is a finite event, but the relationship can be ongoing: a developer selling off the plan over years, a portfolio landlord using one agency, or a buyer's agent who appears in every project. Ongoing monitoring for an agency is therefore both relationship-based and transaction-based. This guide explains how to define review triggers, keep screening current and connect monitoring to the sale workflow without turning every transaction into a paralegal exercise.
Map the relationships that persist
The agency's customer file should record the relationship type and the risk it carries. A repeat seller with a stable profile is different from a developer whose corporate structure changes before every project. Monitoring design should follow the relationship, not just the file.
- Developers and off-the-plan projects that run across many sales
- Repeat sellers and portfolio owners
- Buyer's agents and introducers who appear across transactions
- Entity owners with changing controllers
Define trigger events
Each trigger should map to a response: re-verify the changed party, re-screen, update the risk rating or escalate. The program should name the response so the trigger list is operational.
- A new project or listing from an existing customer
- A change in ownership, directors or trustees
- A new source of funds or payment structure
- An uncooperative purchaser or last-minute party change
- A suspicious pattern reported by the sales team
Review cycles that fit agency work
AUSTRAC does not prescribe one universal calendar. An agency can anchor reviews to transaction events: every new listing, every new sale, every off-the-plan milestone. For dormant relationships, a risk-based periodic review is still needed so files do not age silently.
Record the cycle and the rationale in the program. If the agency uses continuous screening, record how results are received, reviewed and filed; if not, set the re-screening dates explicitly.
Monitoring to reporting
Monitoring has one purpose: to surface what needs a decision. The agency's escalation path should connect the sales team's observation to a documented assessment and, where required, a report.
- Escalate confirmed patterns to the compliance officer
- Assess each pattern against the statutory suspicion test
- Lodge SMRs within the deadline and protect SMR-related information
- Document cleared observations with reasons
Official sources
Confirm the current rules against these primary sources.
Questions
Does a real estate agency need ongoing monitoring?
Yes, where it has ongoing relationships or repeat transactions. AUSTRAC's ongoing CDD framework applies to relationships, and the agency should define triggers and cycles that fit its work.
How often should an agency re-screen a customer?
On a risk-based cycle defined in the program and on triggers such as new listings, ownership changes or suspicious patterns.
What should the sales team watch for?
Last-minute party changes, unexplained funding, third-party payments, cash offers and uncooperative purchasers - and the team should know the escalation path.
Do cleared observations need to be recorded?
Yes. The record shows that monitoring happened and why an observation did not escalate, which is as important as the reports that are lodged.
General information for Australian professionals, not legal advice. It does not replace the AML/CTF Act, the Rules or AUSTRAC guidance. See our editorial standards.
Keep reading
- Real estate checklist3 min
A listing-to-settlement AML/CTF checklist for real estate agents: vendor and purchaser CDD, counterparty deadlines, delayed CDD and reporting.
- Buyer's agents and developers5 min
How Australian buyer's agents, developers and in-house sales teams identify their real estate designated service, customers, start point and CDD duties.
- Ongoing CDD triggers6 min
An operational catalogue of customer events that should trigger AML/CTF risk, KYC, verification, enhanced due diligence and reporting review.